Julian v. MetLife, Inc. et al

Filing 391

ORDER granting 390 Letter Motion for Extension of Time to File. Application GRANTED. The deadline to submit Rule 68 Judgment is extended to May 27, 2022. SO ORDERED. (Signed by Magistrate Judge Barbara C. Moses on 4/28/2022) (rro)

Case 1:17-cv-00957-ALC-BCM Document 391 Filed 04/28/22 Page 1 of 2

Christopher A. Parlo

Partner
+1.212.309.6062
[e-mail]

April 27, 2022
VIA ECF
The Hon. Barbara C. Moses, U.S.M.J.
U.S. District Court for the Southern District of New York
Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, NY 10007
Re:

Julian et al. v. Metropolitan Life Ins. Co.
No. 17cv957

Your Honor:
We represent Defendant Metropolitan Life Insurance Company (“MetLife” or “Defendant”) in the
above-referenced matter. Together with counsel for Plaintiffs, we respectfully submit this letter
requesting an extension of time from April 29, 2022 until May 27, 2022 for the parties to file Offers
of Judgment with respect to Plaintiffs Debra Julian’s and Kimberly Harris’ claims under the Fair
Labor Standards Act (“FLSA”) in the above-referenced matter. This is the parties’ first request for
an extension of this deadline.
As this Court may recall, on March 11, 2022, the parties informed the Court that they had agreed
to resolve Plaintiffs’ remaining individual claims in this case, and requested that any deadline to
seek FLSA release approval be adjourned sine die and that the parties be given until April 29, 2022
to submit Rule 68 Offers of Judgment to the Court resolving Plaintiffs Julian’s and Harris’ FLSA
claims. The Court granted the parties’ application on March 14, 2022. Dkt. 389.
The parties are making good progress on the remaining items which need to be resolved before
the filing of Offers of Judgment. The parties are hopeful that all issues will be resolved in the near
future and that the Offers of Judgment will be promptly filed on the Court’s docket. The parties
therefore respectfully request that the Court allow the parties until May 27, 2022 to submit the
aforementioned Rule 68 Offers of Judgment to the Court.
We thank the Court in advance for its consideration.

Morgan, Lewis & Bockius
101 Park Avenue
New York, NY 10178-0060
United States

LLP

+1.212.309.6000
+1.212.309.6001

Case 1:17-cv-00957-ALC-BCM Document 391 Filed 04/28/22 Page 2 of 2

The Hon. Barbara C. Moses, U.S.M.J.
April 27, 2022
Page 2
Respectfully submitted,

/s/ Christopher A. Parlo
Christopher A. Parlo
cc: All counsel of record (via ECF)

submit